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Policy Impact Testimonials

We've pulled comments out of the public comment folder for CDEC to make them more visible here.

I would like to vote no on the proposed ratio and capacity change.

--Abby Brich Mountain View Academy

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Abby Brich - Mountain View

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Abby Brich - Mountain View

It has been a standard for years to have our ratios 1:12 and it would greatly impact how we run our center and four year old room. This to would greatly affect our budget immensely moving forward.

Abby Nangano--Jacob Academy

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Abby Brich - Mountain View

Creating a rule that changes the the ratio by 2 changes most classroom enrollment by 4. This can create a hardship for providers.  Alicia Lazz -- Endeavor Schools

KinderCare shares the State’s goals for increased access to high-quality, affordable preschool for all Coloradoan families. However, given limited resources and timeframes, reducing the ratio from 1:12 to 1:10 will significantly restrict access for children and increase costs for families. KinderCare currently operates 42 UPK classrooms across our 32 centers in Colorado. We estimate that a reduced ratio will result in 80 fewer families being served through UPK next year across our schools. Such trends will ripple across preschool programs across the state. Our programs must ensure that teachers are paid their promised wages and provide the needed resources for quality programming. A 1:10 ratio will reduce the per classroom reimbursement rate, while the costs of running a quality program are fixed. This will likely require tuition increases for UPK wraparound care and all other age groups at our centers, making full-day/ full-year care out of reach for many families. As a result, this will reduce the UPK cost savings for families – a key and promised feature of the program. We are a proud partner of UPK Colorado and fully understand and see the benefits this program offers families across the state. We hope CDEC will weigh the immediate unintended consequences and consider a more methodical approach to reduced ratio. Please consider KinderCare a partner and a resource in such efforts.

Alison May - KinderCare Learning Companies

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Abby Brich - Mountain View

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Abby Brich - Mountain View

Current Licensing Regulation for 4 year olds is a 1:12 ratio. By reducing to a 1:10 you are excluding 2 to 4 children/families from participating in Pre-K, when spots are already limited. You are also costing childcare centers to lose income, since less families are able to enroll with the same amount of teachers needing to be compensated. Providers do not receive any funding for participating, and taking away part of our income with this ratio reduction will cause current program providers to cease participation.

Amy Hunter - Great Escape Early Learning Center

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Abby Brich - Mountain View

Decreasing the Pre-K ratio from 1:12 to 1:10 would create a financial hardship for our center. As it is, 87.5% of our staff do not earn a living wage. We are also one of the few centers in the area that provide childcare for infants. Infant and toddler care is more expensive to run than preschool care, the 1:12 ratio helps all of our rooms to continue operating.

Barbara Lewis - Summit Early Learning Center

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Abby Brich - Mountain View

The 1/12 ratio for Pre-Kindergarten gives the children proper individual time and is completely manageable to watch the safety of all the children.

Beth McGraw - Primrose School of Centennial

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Abby Brich - Mountain View

Reducing the 4 year old ratio to 1:10 from 1:12 will impact us financially by reducing the tuition from four children in the classroom. Loss of that much tuition has a direct impact on our ability to continue to pay teachers and support staff at a competitive rate and continue to increase their wages with qualifications for a higher quality teacher.

Bethanne Rodriguez - Thrive Preschool

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Abby Brich - Mountain View

The class size should remain licensing group size without the exception requiring a 10-1 ratio and group size 20. Reducing class size will drive up costs, reduce availability and make if difficult for some providers to remain in the program or remain open.

Beverly Maxwell - Advantage Learning Center

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Abby Brich - Mountain View

This rule will make it to where my school will be unable to participate in UPK, as it would cause us to have to cut ten children out of our program. We live in a county that is already considered a child care desert and this would be doing a great disservice to our community. We are working to add licensed slots, not remove them! It is important to remind everyone that it is still possible to have a high quality program with more than 20 children in a classroom. Montessori best practice is actually to have between 28-35 children in a classroom. I recommend that there be a subsection of rules to follow this rule, including the same things that it states in the Child Care Licensing Rules and Regs. Those are as follows: a. Preschool age and school-age groups of children must be separated into developmentally appropriate activities. Groups are not required to be separated from each other by permanent or portable dividers or walls. b. Group size for children in preschool and school-age classrooms may be exceeded for circle time, meal and snack time, special occasions, and activities. c. The licensed room capacity must not be exceeded at any time.

Brianna Myers - Salida Montessori Charter School

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Abby Brich - Mountain View

If implementing max group size of 20 and max ratios of 1:10 then CDEC should increase UPK rates appropriately to offset loss of revenue of having fewer children per classroom and also clearly cite what specific research they're using that shows the benefits of reducing group size from 24 to 20 and ratios from 1:12 to 1:10 so that this can be clearly communicated to the field to show why it's being implemented.

Chris Miller - submitting comments personally

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Abby Brich - Mountain View

This would result in a $164,000 revenue loos for many schools

Crystal Alvarado - The Goddard School Denver

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Abby Brich - Mountain View

We wish to express our concerns regarding the proposed reduction in class size from 24 to 20. While we fully appreciate the intent behind this change, it is important to highlight the significant impact it would have on our ability to offer the Universal Preschool Program (UPK) to our families. Reducing our class size in this manner would have a dramatic effect on our school's operational sustainability and our capacity to effectively support and educate the community we serve.

 

Operating a high-quality preschool program entails various expenses, including staffing, curriculum materials, facility maintenance, and more. These costs are carefully balanced with the number of children we can accommodate in a classroom. Reducing the class size by four students would result in a substantial decrease in our revenue, making it exceedingly difficult to cover operating costs while maintaining the level of excellence we strive to provide. As a school, we have 3 classrooms for our Pre-Kindergarten curriculum. This would ultimately reduce our occupancy size by a total of 12 students if we were to limit our class size to 20 students.

 

Moreover, the reduction in class size would limit the number of families we can serve, ultimately diminishing the accessibility of UPK in our community. We firmly believe that every child deserves access to quality early childhood education, and our school plays a vital role in fulfilling this need. However, the proposed rule would impede our ability to continue offering those services to as many families as we currently do.

We understand the importance of maintaining high-quality standards in early childhood education, and we support efforts to enhance the overall quality of preschool programs. However, we urge the policymakers to consider the potential unintended consequences of reducing class sizes without providing additional resources or support to offset the financial strain it places on preschool providers like ourselves.

 

In conclusion, we kindly request that the proposed reduction in class size from 24 to 20 be reconsidered. We are committed to providing exceptional early childhood education and fostering a thriving community, and the proposed rule change would significantly hinder our ability to fulfill this mission.

Dan Resnick - The Goddard School Arvada (Ward Road)

Greg Armstrong - The Goddard School of Denver

Jarrett Armstrong

Sloan Armstrong - Emerson School

Kirsten/Matthew Samel - The Goddard School Meridian

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Abby Brich - Mountain View

This comment is in response to the proposed ratio of 1:10 in a UPK classroom, which is a decrease from the current 1:12 ratio as mandated by childcare licensing. This will have a large impact on community childcare providers because it decreases the amount of children they are able to have in the classroom and therefore decreases their revenue. I have concerns that the public school system will be better able to adapt to these new ratios due to their stronger financial standing and that this change will have an inequitable impact on community childcare providers. We all know that community childcare providers are constantly and consistently operating on the financial brink, and this decrease in revenue will push them closer to the financial demise. Overall, decreasing this ratio from 12 to 10 children per adult will result in an overall decrease in funding by 17% per UPK classroom. It is vital that we support the ongoing operations of community childcare programs as they are an essential part of the community landscape and overall workforce and economy.

Dora Esparza - Denver's Early Childhood Council

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Abby Brich - Mountain View

UPK programs must be allowed to maintain a ratio of 1:12 in a class of 4 year olds, which is in alignment with current licensing rules and regulations. In Montessori schools which follow a Montessori curriculum, provide the full complement of Montessori materials, and employ a Montessori credentialed teacher to guide and oversee the children in the classroom, limiting group size to 20 and ratios to 1:10 is unnecessary, does not align with current licensing rules, and will affect our bottom line. While a Montessori classroom is normally mixed ages, the fact is that we may see an influx of 4 year olds will put us in the precarious position of having to change our business model somewhat. We have to be able to maximize our space without having to hire additional staff that, heretofore, has not been required by licensing. Consider also the following, per MPPI (Montessori Public Policy Initiative), re: Higher Adult-Child Ratios and Group Sizes "The Montessori classroom is a dynamic learning environment with multiple activities occurring simultaneously. Because the entire classroom is designed to optimize children’s independence, adults are not needed to manage every situation or ‘control’ a group of children. The classroom materials themselves allow children to repeat, and master concepts and explore information. In addition, children learn with and from each other and are not solely reliant on the teacher. Larger class sizes are by design, to give children greater agency over their own learning."

Elsa Ryland 0 Fairview Montessori School

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Abby Brich - Mountain View

no classroom of an eligible preschool provider shall have a staff-child ratio in excess of 1:10 or a maximum group size in excess of twenty (20);

 

Why are you trying to shut us all down??????? Going from 12 kids to a UPK classroom to 10 kids will take away 12 UPK spots in our center. 12 children x $593 per month is $7116 per month with a total of $64,044 per year that YOU ARE ROBBING US OF!!!!!! The State of CO has had a doable 1:12 ratio for years. WHY ARE YOU TRYING TO CLOSE THE PRIVATE PRESCHOOLS!!! WE WOULD CLOSE DOWN WITHOUT THE $64,044 PER YEAR THAT THOSE 12 CHILDREN BRING IN.

Heather Henz - Our Fathers Children's Learning Center

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Abby Brich - Mountain View

I was under the impression that the basis for UPK was to allow for more children to have access to Preschool and Pre-Kindergarten programs. This proposed change directly contradicts that. Not to mention, that for successful private Preschools, we already have a full class expected for Pre-k next year. In order to participate in UPK, we would need to kick families out of our school if the ratio is decreased. What you are proposing will take away roughly 80-100k from our programs, when we are already struggling. The UPK stipend will not come close to covering that. With the rising costs of supplies, insurance, materials, rent, taxes and labor, most of us can not afford this change, and would opt out of participating next year. Please reconsider.

Heather Pilletere - Goddard School

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Abby Brich - Mountain View

Decreasing our licensing ratio from 12 to 10 in the classroom will make it very challenging for our center. We would like to request you keep the classroom ratio to the licensing requirements.

Jori Flores - Wray Community Learning Center

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Abby Brich - Mountain View

To ensure our staff has livable wages, a classroom cap size of 20 is unrealistic to maintain quality standard, hire the appropriate assistants, pay rent and keep up with other expenses. Unless the hours paid for by the state are raised significantly and per pupil funding is increased, this is unreasonable.

Kelly Gomes - Wildflower Montessori Public Schools of CO

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Abby Brich - Mountain View

By reducing the current licensing ratio for 4 year old children from 1:12 to 1:10, this is a potential loss of almost $4,000 dollars a month. This would definitely hurt our program and I'm sure many others. Please keep the 4 year old ratio at 1:12.

Deanna Otto - Licensed Child Care

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Abby Brich - Mountain View

We currently have 40 UPK students in our school. We run a 1:12 ratio in those classrooms. If this rule is passed we will lose 4 students. We can not afford this and would be forced to no longer participate in UPK. Please do not make this change as it will not only affect us but also the families in our community that depend on care at our location.

Kim Bourgain - Primrose School of Longmont

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Abby Brich - Mountain View

The requirement of having a maximum group size of 20 in our UPK classes will cause us to rethink the business model, most likely by raising UPK tuition. In turn, families can expect to pay more negating the benefits of UPK funding. To help keep providers on a fair playing field, similar to how UPK considers all types of providers, CDEC needs to consider eliminating property taxes for UPK providers, most likely in the form of a tax credit due to the restrictions of the CO constitution. School districts can adjust their class size more easily, because of how they are funded. A private provider works with ratios and tuition to make the school financially feasible. I can support the 10:1 ratio with a tax credit to lessen the property tax burden.

Lance Shimomura - Goddard of Northfield

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Abby Brich - Mountain View

This will directly affect the cost income to our program. We cap our classed at 14 with 2 aides for or 4 year olds or we cap at 12 with no aide. The ratios already are a constant commitment in taking care of teachers and kids with breaks and safety always in place. Please don't change the ratios for UPK. Please keep them inline with our licensing standards.

Leslie Chrysler - Twin Peaks Preschool

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Abby Brich - Mountain View

I disagree with changing the current ratio of 1:12 to 1:10. This would require additional staff or space which we do not have funds or space to do so. Please leave the current ratio for pre-k 4 at the current ratio of 1:12.

Margie Wass - Independence Academy  Charter School

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Abby Brich - Mountain View

This will decrease our 4 year old classrooms from a 1:12 to a 1:10 ratio which means a decrease in those classrooms by 4 children each. This change will cost our school financially. If we stand to lose capacity in your 4 year old rooms...how do we stay stable as a business??

Maria Emmanuelli - Primrose Schools

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Abby Brich - Mountain View

Running a UPK program with a 2:20 ratio is a loss in revenue to the school that will DIRECTLY impact quality standards. Loss of revenue on 4 students at the UPK rate of $595.00 per student (which is already far below what it should be) is equivalent to staffing the program with an additional teacher - or paying a higher wage - for the teacher. We would need to make CUTS to our program if we are losing 4 enrollment spots to UPK.

Melanie Gilbertson - The Goddard School Fort Collins

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Abby Brich - Mountain View

I am writing to express my concern regarding the reduction of class sizes from 24 to 20. I have the unique perspective of beginning my career as an early childhood teacher before transitioning to owning a center. I understand the importance and impact of providing high quality both for our children and our faculty. I agree that lower classroom sizes and ratios are a marker of high quality. However, it is not the only thing that determines a high-quality program, nor does it guarantee that a program is high quality. This is exactly why there are various metrics to measure quality in Colorado Shines Quality Rating and Improvement System. Metrics that respect the various early childhood philosophies and business models. As a center we have now gone through our Colorado Shines rating twice. With our most recent rating, we increased our quality to a Level 4, while still maintaining standard state ratios in all our classrooms. This included 24 children in our 4-year-old classrooms. From the beginning, I have been a proponent of UPK and what it meant for our community at large. From the community perspective, it meant that I could bring in families from our community who would not normally be able to afford care at our center. It meant that I could afford to enroll a family of 3 siblings on CCAP, including twin 4-year-olds and their younger 3-year-old sibling. It meant that our teachers of children in our UPK program did not have to pay any tuition. We are a program that runs two UPK classrooms. The proposed rule means that we would reduce our classrooms by 8 full time slots. If this rule is approved that means the displacement of 8 families. Though UPK increases the affordability of early education, this rule could decrease its accessibility by upwards of 16%. Outside of the impact on our community this rule will also have a substantial financial impact on my ability to provide the high-quality care that our families and faculty are accustomed to. The approval of this rule would result in a substantial decrease in our revenue, making it exceedingly difficult to cover operating costs while maintaining the level of excellence we strive to provide. This includes the cost of staffing, curriculum materials, facility maintenance, and much more. These costs are carefully balanced with the number of children we can accommodate in a classroom. It is because of this balance that we can provide competitive wages, competitive benefits, tuition reimbursement, paid professional development and a minimum of annual wage increases to our faculty. It also allows us to maintain quality materials in the classroom that are always in good repair. I understand the importance of maintaining high-quality standards in early childhood education, and I support efforts to enhance the overall quality of preschool programs. However, I urge the policymakers to consider the potential unintended consequences of reducing class sizes.

Naomi Esquibel - The Goddard School of Arvada

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Abby Brich - Mountain View

Most centers with preschool classrooms were built to have 24 Four year olds and run at a 1:12 ratio. You CAN'T mess with individual businesses that choose to run their UPK classrooms at 1:12 ratio, max 14 students when their budgets depend on it. This alone will cause programs to opt out, or put a strain on programs to the point that THEY WILL CLOSE. Programs with inf/tod need the additional tuition dollars gathered from the Prek class to pay for the expensive overhead to RUN THE ENTIRE SCHOOL. This is the worst idea in the whole rule set.

Pam Melot - Creative Learning Preschool

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Abby Brich - Mountain View

My wife, Julie, and I operate The Goddard School in Louisville, and we have been happy with the success of the UPK program for this school year. We hope to be able to continue to serve our community in this mission of Early Childhood Education. However, I wish to express great concern over the proposal to reduce class size in the Pre-K program from 24 to 20 students. This action will have a dramatic impact on the viability of the high quality program that we operate. It is no secret that the private preschool industry operates on fairly thin margins. Without going into detail regarding all of the expenses that go into providing a high quality program, I will point out that cost of labor is more than half of our total expense. While this proposal would not lead to ANY reduction in expense, it will impose a reduction of 16.7% in revenue. This would not be sustainable. I support the efforts to enhance overall quality the UPK programs, however, policymakers need to understand the consequences of such a change. We hope to be able to continue to participate in the UPK program. Don’t hesitate to contact my wife or me for clarification on our perspective.

Rick Avirett - The Goddard School

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Abby Brich - Mountain View

Changing the ratio for UPK classrooms from 1:12 to 1:10 would bring a hardship to schools financially. This would decrease the number our overall number for Pre-K by 8 full time spots. Our Pre-K program is full. Decreasing the spots will in turn cause a hardship on families looking to enroll in our program.

Sarah Cleary - Primrose School of Parker

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Abby Brich - Mountain View

Please do not change the ratio to 1/10. We have a hard enough time providing benefits and high wages, if we lose 8 students from our two pre-k classrooms it will be so hard to keep up with staffing correctly and paying well.

Shannan Meyer - Primrose School of Parker, Centennial and Lowry

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Abby Brich - Mountain View

It does not make sense to limit class sizes beyond Child Care Licensing. When providers open their doors to students, they create budgets based on the number of students and teachers. Limiting class sizes beyond Licensing regulations not only will decrease significantly the number of Pre-K spaces available to working families who need high quality education and child care, but also puts providers who rely on the revenue at major risk of not being profitable. If they are not profitable they will continue to pass down even higher costs to families and potentially risk closing down and not being able to serve Pre-K families let alone all the other age groups served already at lower profitability due to class size restrictions. If Universal Pre-K class sizes are limited, funding needs to be increased by 25-50% in order to make up the difference in tuition that will be needed to lose that much revenue.

Shannon Doyle - The Goddard School

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Abby Brich - Mountain View

It is and extreme financial burden to impact a 4 year old classroom by 4 children going from 1:12 max of 24 to 1:10 max of 20

Stephanie Branscum - Primrose School at Standley Lake/Reunion

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Abby Brich - Mountain View

Changing the standard ratios may seem like a great idea at first glance. It will certainly have a trickle down effect that will not be as positive. As with all small businesses, we run on a tight budget. Each teacher has a contract for a certain amount of money and I am able to keep amazing, qualified teachers by paying them a decent wage (current budget of $22-$28 per hour per teacher and they are worth much more). The proposal to lessen the ratio of children per teacher reduces the amount of monthly tuition I am able to collect per classroom which directly impacts how well I can pay teachers. We have enough trouble finding and keeping great teachers at the current rates, and we may not be able to do that if we are forced to reduce hourly wages. The rest of our budget is fixed costs (contracted rent and utilities, insurance, supplies, social security, food, ongoing State required training and other early childhood requirements to keep our license) so the only area that we are able to make up the difference is in teacher wages. I can't imagine that the goal of this proposal is ultimately reducing already low teacher wages, but that is what will result if this moves forward. Our school and our teachers believe that the current ratio in Pre-K classes of 12 children to 1 teacher is adequate and still provides a quality environment and early education for our kids. At this age, 4-year-olds are much more independent and capable - it doesn't require the attention and management that a 3-year-old classroom takes. The Pre-K kids are forming friendships, are capable of independent play, can listen and follow directions. For the past 40 years, I have watched our Pre-K classes successfully grow socially, emotionally and academically. In contrast, a smaller class of 10 children per teacher does not provide as much social interaction or growth that a slightly larger classroom offers. A smaller class also does not set the kids up for success to enter Kindergarten. Most Kindergarten classes have 24 to 32 kids and only one teacher. Pre-K kids need to start developing the skillsets this year (mainly increased independence) in order to be successful in future school years. Instead of reducing children to teacher ratios, there are other solutions that could accomplish similar goals. For example, at our school, one of the requirements is that each family has one adult that volunteers in each of our classrooms once every 2 months for the school day. Parents love to come and see their child in action and it changes our ratios (one additional adult with the same number of children which makes the ratio even lower than what is currently proposed). Also, there are many seniors and or retired teachers that would love to volunteer in classrooms across the State and this would certainly change the ratios for the better for all schools. The cost to have them fingerprinted and onboarded would be manageable compared to cutting thousands of dollars promised to UPK providers when we originally signed up to be a UPK provider last year. The UPK program has been a rollercoaster ride from the start. I signed up to be a UPK provider because I saw the benefit of offering my families the financial benefits the State offered to 4 year old's. What I did not anticipate was the hours and hours of extra time and confusion that I would spend to put UPK into action at our school. The rules changed over and over again, and the timeline changed constantly. Now, less than a year after implementing this program, the agreement between Providers and the State is proposed to drastically change severely cutting our budget. This proposal only helps the State's budget. We are talking about 2 kids per teacher and perhaps the State needs to compensate the Providers for the lost tuition per teacher if this is the ultimate solution for 'Quality'. In conclusion, I ask that you 'think outside the box' when trying to incorporate 'Quality Standards' into our classrooms. Please do not take away monies from small preschools as your first and only option. Teaching isn't easy - you really must want to make a difference in early childhood education. As a teacher, feeling like you are being fairly compensated for all the extra time and work is essential. As a preschool owner of a small non-profit, I certainly cannot afford to lose my qualified teachers to another field. Good teachers are a commodity and in short supply, and this proposal seems to be contradicting all of the other State's efforts to value early childhood education and its teachers.

Vanda Klimpke - Child Priority Preschool

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Abby Brich - Mountain View

he staff-child ratio should be the normal ratio for the age group, 1:12 to support staffing in the age. This would greatly support the teachers in having access to planning time and being able to break, especially during a time when qualified staff are so hard to come by.

--Abby Hoese JCC of Denver Early Learning School

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Abby Brich - Mountain View

I do not think the ratio needs to be moved to 20 children, the state licensing has allowed 24 total for 48 months and older. This takes away 4 spots from children.

Alicia Boykin 0 Little People Landing - Parker

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Abby Brich - Mountain View

The ratio for 4 year old is 1:12 and that is a workable ratio for the age group. My Pre-k room is licensed for 24 kids. Making this change would reduce my enrollment by 4 children which is $62,000 a year is lossed revenue. This is a huge financial impact for my small center. Please leave the UPK ratio in line with the State ratio of 1:12 and not change to 1:10.

Allison Gooding - New Beginnings Child Care

I currently offer services to 36 Pre-K students, 3 of which have late Aug/Sept dates of birth and their parents opted for an additional year of Pre-K. Which come to 33 students who are in Colorado's UPK. I have a Pre-K classroom for 24 and one for 12. With the proposed change to 1:10 with max class size being 20, I would have been unable to offer Pre-K services to 6 students this year. The amount of revenue lost would be $10,410/month, which comes to a loss of revenue for the 9 months of the school year totaling $93,690. If this rule change goes into effect for 2024-2025, I will not be able to accommodate the students I currently have in my 3-year-old classrooms that will become eligible UPK students for the upcoming school year. I currently have 38 between the two 3-year-old rooms that I have. In order to meet the ratio and max class size that is being proposed, we would actually have to turn away some of our current students who have been with us in most cases since they were infants. Additionally, we would have to charge for an exorbitant amount for wrap around care to make up this difference, most likely about $300-350 more/month. All of this would be unfortunate to our families that chose our center. We are already running on a tight budget and the profitably of my school is a thin line. I have very capable teachers that can successfully manage a 1:12 ratio classroom. Our school opened 22 years ago and 1:12 have always worked for us. Our Pre-K students leave here to go to kindergarten, well prepared.

Amanda King - Blue Sky Kids, Inc

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Abby Brich - Mountain View

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Abby Brich - Mountain View

If the state mandates that we decrease our UPK ratio to 1:10 for 4 year olds, this will dramatically impact our staffing. We are a brand new center (just over one year old) and we are barely keeping afloat financially as it is. This would force us to add 2 more people each for a half day. When UPK already dropped their funding for us from $660/wk to roughly $580/wk, we immediately lost $1760/week or $7K a month. That was a huge hit we were not expecting. Then adding extra staffing on top of that would crush us. Please don't do this!

Amy Maliberger - NOCO Kids Academy

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Abby Brich - Mountain View

While changing ratios to 1:10 will increase capacity for public schools, it decreases our capacity at all 3 locations by 4 students each. That is $1500 a week. Our budget can not sustain that type of hit without increasing tuition to the parents who remain. Why would we give a UPK discount of $125-$150 a week to only have to raise rates by $75 to make up the difference of losing 4 children. It does not make any sense!!!

Becky Sundeen - n/a

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Abby Brich - Mountain View

EPIC believes that research on early childhood education generally supports the ratio and group size proposed in this ruleset. However, we would like to express concern that this ratio does not align with licensing requirements, which may result in a burden for providers. We urge the department to recognize that providers are typically subject to several different types of regulations and every instance where these requirements differ creates additional burden. Reducing ratios and group sizes in classrooms impacts profitability of a preschool provider, particularly if they are a community-based program dependent upon profit margins earned for preschool-aged children to maintain infant and toddler classrooms. We also recognize that many classrooms are not large enough to accommodate more than 20 children. With this in mind, we would encourage the department to determine how many providers in the state would be able to accommodate more than 20 children in a classroom and potential financial impacts for preschool programs if they were not bound by these rules. This data would help to determine whether this inconsistency is creating a significant burden for providers.

Beth Melton (EPIC)

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Abby Brich - Mountain View

The ratio 1:12 for a four year old classroom has been a standard for many years and has worked great in all our 4 year old classrooms. Changing it now would impact our budget immensely.

Brittany Duvall - Jacob Academy (2nd location)

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Abby Brich - Mountain View

Ratio should stay 1:12. It should not change 1:10. This will hurt businesses.

Caitlin Ellis - Little People's Landing (2nd location)

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Abby Brich - Mountain View

The proposed class size cap of 20 students would significantly impact the financial viability of our program by reducing our revenue by 17%. As a small program with limited resources, this cut would be extremely difficult to absorb. Please consider allowing an exception or waiver for established dual language immersion models, so innovative programs like ours can continue providing quality language education to students. The dual immersion model has unique staffing and classroom needs due to its dual-language structure.

Chen Hong - AXIS International Academy 

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Abby Brich - Mountain View

This is going to be a hardship for our school where we staff to have 1:12 ratio as we have 4 year olds only in these rooms. This is licensing rules and regs for early childhood and should not be changed.

Claire Southard - Highlands Academy

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Abby Brich - Mountain View

All ratios should stay the same. Our 4 year old classroom is 1-12 with group size of 24 and that makes a great class size for the children and all the supporting staff. 7702.46 14 and 15. Changes this ratio would cause undue burdens on an already struggling industry.

D'Arla Mezzacapo - Take a Break

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Abby Brich - Mountain View

Please continue to have 4 year old classrooms ratios be 12:1 instead of the proposed 10:1. If changed this new rule would reduce how many facilties would be able to accept UPK and reduce the publics access to UPK. There is no reason to reduce the ratio from 12 to 10. At my school 12:1 is perfectly safe, with quality care and education. If reduced to 10 we would not accept UPK children which would just reduce the amout of families that are helped by this program, this is exactly opposite of the programs goal of helping UPK familes afford programs like ours.

Daniel Meyer - Primrose School of Centennial

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Abby Brich - Mountain View

Ratios do not need to meet NIEER standards to reflect quality. 4 year old classrooms cannot afford to have their ratios decreased to a 1:10 ratio. This takes us one significant step away from a mixed delivery system. Let your program inform national policy with amazing outcomes at the 1:12 ratio!!! ECEA is attempting to support private engagement but it is going to be significantly more difficult when people see a rule like this passed. Stand with licensed programs and set ratios at the existing licensing ratios.

Dawn Alexander - ECEA of Colorado

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Abby Brich - Mountain View

A reduction in ratio and capacity sizes would negatively impact the amount of 4 year olds we are able to serve at our school, which is contrary to the mission and vision of the UPK program.

Deanna Constantine - Highlands Academy

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Abby Brich - Mountain View

By reducing the current licensing ratio for 4 year old children from 1:12 to 1:10, this is a potential loss of almost $4,000 dollars a month. This would definitely hurt our program and I'm sure many others. Please keep the 4 year old ratio at 1:12.

Deanna Otto - Licensed Child Care

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Abby Brich - Mountain View

This will severely affect our ability to run an early learning center that is already under pressure from the reduction in children due to schools receiving more funding hours than early learning centers. As the experts in delivering quality care for working families this rule makes no sense in an environment of higher and higher wage competition and

Edward Southwick - Children's Lighthouse Parker

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Abby Brich - Mountain View

We were surprised by the proposed change from class size of 24 to class size of 20 in the UPK classrooms for students 4 years old and older. A loss of capacity of 4 students in each pre-Kindergarten (4 year old and older) class for the upcoming school year without corresponding financial support for loss of those 4 spaces would require our early learning center to reconsider our participation in the UPK program. For four full time students at our schools, this is well over $50,000 in revenue per classroom for a nine month period. We understand and support the value of close student-teacher interactions, but the ability to have qualified faculty to support those interactions depends on the financing to back it.

Elizabeth Meier - The Goddard School - Denver (2 locations)

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Abby Brich - Mountain View

Thompson Valley Preschool, Inc. (TVP) does not support the proposal to decrease 4 year old classroom ratios from 1:12 to 1:10. This action would decrease the number of Pre-Kindergarten slots overall in the community leaving families in need of services, and decrease the income of centers which are already stretched financially.

Gail Yant - Thompson Valley Preschool, Inc.

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Abby Brich - Mountain View

Do not lower UPK rate to 1:10

Gina Vaughn - Child Care Center

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Abby Brich - Mountain View

The ratio for 4 year old classrooms needs to remain at 1:12. This allows for 2-4 more children to receive services, and for the staff to take breaks during rest time. While the ratio is lower than this at most times during the day (1:8 to 1:10), the 1:12 ratio is consistent with licensing requirements and is much needed for as many children as possible to receive services and also allows for staff breaks. It would be a detriment to child services to change it to 1:10.

Gloria Roggow - St. John's Lutheran Preschool

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Abby Brich - Mountain View

Leave the 4 year old ratio at 1:12. Changing to 1:10 will require we reduce our capacity by 17%, the most likely scenario due to room size and proposed group size. This would be the equivalent of 1/2 the pay of one UPK teacher. We may even be forced to opt out of participation in the program. A mixed delivery system that provides full education AND care for working parents will be undermined. 1:12 ratio has been proven safe and effective for years, there is no reason to hamstring private providers and cut jobs. Again, we can’t just hire more teachers because we cannot (and will not) exceed group capacity.

Hannah Walker - Thomas Learning Centers

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Abby Brich - Mountain View

Changing ratios and group sizes will negatively impact my schools

Holli Martin - Highlands Academy, Centennial Montessori, Mountain View Academy

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Abby Brich - Mountain View

Lowering the 4 year old classroom ratio from a 1:12 ratiio to a 1:10 ratio would result in a $2,000-$4,000 a month and $24,000-$48,000 yearly reduction in revenue per classroom. Rates would need to be increased at a significant rate per child to offset this loss. With families already economically stressed this would create unnecessary hardship. As we try to maximize wages to our staff this could have a detrimental impact there as well.

Jami Murphy - Bright Start

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Abby Brich - Mountain View

This does not match what the ratios of the State are. This decreases the ammount of students we can have, and how many teachers needed for 4yr olds. This would make it difficult for my center to stay funded.

Jenae Lato - Peace with Christ ELC

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Abby Brich - Mountain View

Please leave 4 year old ratio at 1:12. Changing to 1:10 will require we reduce our capacity by 17%, the most likely scenario due to room size and proposed group size. This would be the equivalent of 1/2 the pay of one UPK teacher. We will likely be forced to opt out of participation in the program. A mixed delivery system, that provides full education AND care for working parents will be undermined. 1:12 has. been proven safe and effective for years, there is no reason to hamstring private providers and cut jobs. Again, we can’t just hire more teachers because we cannot (and will not) exceed group capacity.

Kelly Boerder - Lakewood and Westminster Learning Center

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Abby Brich - Mountain View

Lowering the pre-k ratio from what is currently allowed by licensed 1:12 to 1:10 will have a significant impact on the viability of our center. Not only will we be losing $43,000 to $86,000 (2-4 students), we would have to hire at least 1, if not two, additional teachers to accommodate the lower ratio. Those could add up to a catastrophic shortfall in our budget. We would consider not participating in the UPK program if this rule change goes into effect, as it wouldn't be worth it to our center.

Kerri Brown - Park Hill Children's Center

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Abby Brich - Mountain View

Rules Regulating Child Care centers states the children 48 months maximum group size is 24 with a child to teacher ratio of 1:12. Participating in UPK would require the loss of 4 slots and a loss of revenue. This puts a large hardship on the private providers in which facilities are constructed based on the state required group size and ratio.

Krista Bielat - Early  Learning Academies

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Abby Brich - Mountain View

We should not be limited to a max group size of 20 or be kept to a 1:10 ratio. Our classrooms run at 30 children with 4 Group Leads in 2 separate groups. In the afternoons, we run 1:12 with our 4-5 year olds per licensing regulations. This rule will require us to disenroll 30 children to maintain UPK for our families which loses the mixed delivery system and puts families out of care.

Laura Kent

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Abby Brich - Mountain View

If you decrease the ratio it will effect our centers bottom line.

Leatha Peats

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Abby Brich - Mountain View

There is no reason to drop the ratios for childcare as a whole for Preschool ages if it is only effecting the public school systems. By decreasing our ratio that is lowering our enrollment by four children which our budget does not allow.

LeeAnna Shattuck - Jacob Academy (3rd location)

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Abby Brich - Mountain View

Keep licensed programs at a ratio of 1:12 for Pre-K classrooms. Lower our ratios to 1:10 may prohibit many programs from participating. Public programs may benefit from a 1:10 ratio and may have special needs children in their classrooms which justifies the lower ratio. Private programs do not typically have as many special needs children since they are required to go to a public school to receive services.

Lynn Rodenhizer - University of Colorado

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Abby Brich - Mountain View

Changing the teacher:child ration will result in a 20% loss of income. Small center operators in Denver County face a minimum wage of $18.29 on 1/1/2024. Of course, our teachers' salaries will be higher, but this rule will jeopardize seriously our financial viability. Please maintain the current CO State regulations ratio of 1:12 and a group size of 24. Please give providers the option but not the requirement of reduced class sizes and teacher:child ratios.

Mary Jane Rafferty - 5 Centers: University, Stout Street, Colonnade, Porter and Commerce Children's Centers

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Abby Brich - Mountain View

Limiting 4 year old programs to a ratio of 1:10 will take away much needed slots for programs that are struggling just to stay open. While the payment provided per student is a good rate, it in no way makes up for the potential loss of revenue that taking 4 students away from each large classroom will create. The sheer number of students in a classroom is not the best indicator of quality. Ensuring staff are properly trained, that they have the supports and resources needed for their classrooms are better indicators of a quality program.

Melisa Guggenmos - City of Aurora Preschool Programs

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Abby Brich - Mountain View

Change the staff-child ratio from a maximum of 1:10 to 1:12 Change the maximum group size from 20 to 24 Rationale: From the experience we’ve heard from ECE center owners directly, it can be extremely difficult to operate a financially viable business with staff-child ratios as low as 1:10 or maximum group sizes of 20 children. Research also does not support that ratios of this size necessarily equate to better quality childcare. A 2017 report found that, “…better ratios in preschool-aged ECEC classrooms are not associated with better outcomes for children. This is consistent with findings from large-scale meta-analyses examining teacher-student ratios and student achievement in formal education systems.” Further, the study found that, “…within the range of permissible child-staff ratios, variations in ratios have small, if any, associations with concurrent and subsequent child outcomes.” Finally, we know that the margins for financial stability in the childcare industry are extremely low. According to the U.S. Department of Treasury’s 2021 white paper about the child care industry, “The average child care center operates on razor thin margins of less than one percent (2021)”. Additionally, according to analysis by the National Center on Early Childhood Quality Assurance (2014), ECE centers of no more than 20 children are barely financially viable. The change in ratios can make or break many small childcare center’s financial viability for the future. The UPK program was put in place to bring relief to parents/families across the state, but not at the detriment of child care centers. Sources: Early Care and Education Program Characteristics Early Care and Education Program Characteristics: Effects on Expenses and Revenues. 2014. https://childcareta.acf.hhs.gov/sites/default/files/pcqc_ece_characteristics_final.pdf

Miguel Lovato - Donnell-Kay Foundation

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Abby Brich - Mountain View

My comment is regarding the teacher to student ratio of 1:10. Current state licensing regulations allow for a ratio of 1:12 and decreasing that ratio to 1:10 (with a max class size of 20) affects us tremendously in terms of our ability to participate in the UPK program going forward. We current have 2 Pre-K classrooms with a capacity of 24 children each. If the new rules are implemented, we will lose 8 spots which is very detrimental to our business and we will not be able to bear this loss. We will therefore be forced to NOT partner with UPK going forward. I'm sure this case applies to most private preschools and most of them will be forced to make a similar choice. We would like to propose that the ratios are kept in line with Colorado State licensing regulations of 1:12 (with a max class size of 24).

Nik Saluja - Primrose School of Saddle Rock

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Abby Brich - Mountain View

1:12 ratio has always been the ratio for 4 year olds - this will cut so much of our budget - please do not change this ratio

Penny Gautier - Jacob Academy

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Abby Brich - Mountain View

By reducing the ratio in UPK classes from 12 to 1 to 10 to 1 will be a significant financial stain on childcare providers and families as it will significantly increase the cost of childcare without adding much if any additional benefit for the children.

Raymond Verlinde - HighPointe Academy of Castle Rock

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Abby Brich - Mountain View

We cannot afford a drop from 24 to 20 students in our UPK rooms. At our current rates a loss of 8 students across two Pre-K rooms would cost our school $14,300 per month and $171,600 per year!! That is 8.5% of our revenue, which would make it impossible for us to continue offering UPK without raising our Pre-K rates a minimum of 26% for the other 40 students to make up for the $171,600 loss. Also, by reducing all school from 24 to 20 would eliminate hundreds if not thousands of available spots for students thus shutting out students who would otherwise attend, which goes directly against the mandate of this program. Additionally, if this rule passes we will join with other schools proposing a class action lawsuit against the state and individual members who are leading this change. We offer an excellent program and believe the current 1:12 ratio for UPK provides the greatest opportunity for both students and schools to thrive and succeed.

Ron Montoya - The Goddard School

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Abby Brich - Mountain View

As advocates for high-quality early education programs, we support and share the goal of providing a high level of individualized attention and frequent child-teacher interactions throughout our classrooms. That said, the proposed reduction in ratios and class sizes comes as a surprise as this had not been included in earlier iterations of the quality standards and is a departure from licensing rules. This new change, if implemented quickly and with no additional support, will have a significant and likely detrimental impact on the availability of preschool slots, cost of wrap-around care for families, and to program budgets. As Colorado already has a significant shortage of child care and preschool spaces—higher than that of other states—it is critically important to consider how this policy might impact the broader early childhood landscape for both families and providers. With the proposed class sizes, one in six UPK students in our programs–442 of our 2,650 UPK students this fall–would need to find other arrangements. These students would fill more than 22 new classrooms. Developing appropriate spaces and hiring qualified staff to open new classrooms for these children will take time and resources. The impact to program budgets in current classrooms will take a significant hit, jeopardizing ability to pay staff appropriately, and ultimately, to recruit and retain a high-quality workforce. 1. Increase UPK reimbursement rates to appropriately compensate for the 16% reduction in class size. Providers have built their budgets around the licensing requirements of 24 in a classroom, and many have already posted tuition rates for 2024. Implementation of lower ratios will only be feasible if CDEC provides rates commensurate with the differential. As UPK exists as part of a broader care ecosystem in community-based centers, implementation of the lower 1:10 ratio may effectively reduce overall classroom enrollment and center capacity, and/or increase the overall staffing levels required to ensure centers remain within all applicable ratios during program hours. Any of these foreseeable consequences would increase the already-high cost of quality care for Colorado families. Applying this policy without corresponding rate changes will significantly impact cost savings to families, which is a key and promised feature of UPK. 2. Require the UPK ratios only for the core 15 operational hours each week covered for all families through the program, which would allow licensing ratios during other hours of the day. Though implementation of different classroom ratios will be operationally challenging, requiring the UPK ratio during core operational hours only would give providers at least some flexibility in the morning and afternoon/evening when staffing is most challenging. There may be other ways to provide flexibility across communities that CDEC should consider; we are happy to help you think through and evaluate various approaches. Otherwise, a referenced above, this policy may inadvertently reduce total classroom and center capacity. 3. Phase this requirement in over time; by methodically reducing ratios to 1:11 in SY25-26 and evaluating the impact before moving to a 1:10 ratio in SY26-27, providers and families will have more time to plan and budget for the change. CDEC would then also have enough time to evaluate the impact on availability and cost of care. This timeline also allows for a planned expansion of preschool classrooms to accommodate smaller class sizes. Immediate implementation would have a detrimental impact on availability of community-based preschool options for families. To reiterate, ECEC shares CDEC’s goals of providing high-quality preschool services. However, if implemented now under existing reimbursement rates, this policy will jeopardize the state’s goals of providing high-quality, mixed delivery preschool to all families across Colorado. We would welcome further conversations with CDEC to help evaluate the impact of this policy and work towards a more comprehensive solution to ensure UPK continues to be a success.

Sarah Mercer - Early  Care and Education Consortium/Brownstein

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Abby Brich - Mountain View

It is unacceptable for this organization to randomly restrict preschools to a group size of 20. The Rules Regulating Child Care Centers allows for a waiver of group size in alignment with student:staff ratios. My school has a waiver to allow for a group size of 30 based on the Montessori Philosophy. We have operated safely and effectively with this waiver for 8 years. The intent of UPK was to make more seats available for children - the net effect of this rule would be to reduce the number of available seats in my school alone by 40 (10 students per room in 4 classrooms). Thank you for reconsidering this ruling and including a pathway for schools such as mine that have a group size waiver to continue to participate in the UPK program.

Wendy Renee - Montessori del Mundo

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Abby Brich - Mountain View

The ratio for the Pre Kindergarten classroom (4 years old) should remain at 1:12 with the max capacity of 24 students in the classroom

Yasamin Morhed - Primrose School at Lowry

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Abby Brich - Mountain View

Thank you for allowing schools like mine an opportunity to respond to the proposed rule changes. The rule change reads that the maximum statewide ratios will be maintained, but then, goes on to clarify that a maximum class size can't exceed 20. I am unclear if the term "Preschool" is used interchangeably with Pre-Kindergarten or if this is a rule only affecting the 3 years old classroom. Clarification needs to be provided here. The state ratio for Pre-Kindergarten (4 yrs) is 1:12 with a class size of 24. If the rules are only affecting Preschool education (3 years), I have no issue, because the state ratio for age 3 is 1:10 or 20 total. If the rule, however, intends to lower class sizes for the 4 year old age groups, then I would like to submit the following response for your review. I have owned the Aurora South location of The Goddard School since 2008. We have operated our Pre-Kindergarten program per the state ratio of 1:12 (24 total class size) since we opened. Our quality of education is a benchmark in the Cherry Creek School District for Kindergarten preparation, consistently receiving accolades from the teachers who receive our students into the elementary schools, the parents who witness first-hand the superior results of our program, and others who are familiar with our reputation in the community. Program excellence, as I have come to learn, has little to do with operating at a lower ratio, but rather, a thoughtful curriculum, a purposeful scope and sequence, differentiated curriculum to meet all learners needs, and a creative use of materials and environment. The proposed rule change, no doubt, was born of very good intentions. The fewer the students, the better the education, right? Actually, most education theorists speak about a 1:4 ratio being the ideal learning mix as most leaders in the industry widely accept that small group learning is superior to large group learning. While 1:4 is an ideal grouping, this ratio is cost prohibitive in virtually all private and public school settings. However, we have adapted our classrooms, industry wide, to provide what we call small group learning centers. Schools like mine, using this approach, are referred to as center-based environments. Why do we do this? Simply put, we can achieve the ideal learning ratio but still operate within the maximum allowed group size. In this widely accepted classroom setting, it doesn't matter whether we house 20 or 24 students, because both classroom sizes would operate in virtually the same manner. Multiple interest table centers accommodate 4 students at a time allowing small groups of children to interact with our pre-created games and materials. Teachers, then, engage students in open ended questions that lead to thoughtful discovery. Teachers can focus on handwriting, sight words, math, STEM and phonics skills with such success that all 24 children (assuming they are of normal learning ability) can enter Kindergarten reading and computing at a much higher level than their peers. To reiterate, lowering the class size to 20 won't improve our results, because it doesn't change how we approach our students' education. It is still a large group that we will break up into small groups to provide purposeful instruction. The benefit of the proposed rule change is, at best, neutral in the child's overall learning experience. However, the negative financial impact on the schools, the decreased number of children served in a community and the ability to maintain reasonable tuition rates for families that count on us for more than 15 hours per week, is not unknown. It is quantifiable and disastrous to any private program that serves its community with every bit the good intentions of those that seek to make the change.

Brooke Wright - The Goddard School

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